Keep going, you are close to achieving ADIT success!

In the final edition of ADITextra for this semester, we discuss exam technique for the Principles of International Tax, Transfer Pricing, UK & US Tax exams. 

 

1. Transfer Pricing

To help you achieve ADIT success in the transfer pricing module, we look back to Jimmy Ryan’s final words of advice to our students:

  • Keep going with your studying, there’s not long to go now!
  • Work on your exam technique by practising past exam papers.
  • Use your 15 minutes of reading time wisely to work out what you are being asked in each question.
  • Don’t panic or get intimidated by the questions.
  • Think about the order to do the questions in – Jimmy’s recommended approach is Section C, followed by B and then the compulsory questions in Section A.
  • Read the requirements carefully and do everything you are being asked to do.

 

To benefit from Jimmy’s expertise, book now for the December 2021 Transfer Pricing course, with the added benefit of an attractive early bird booking offer!

 

2. Principles of International Tax

The Principles of International Taxation students exam has a different structure to the other modules with two sections:

  • Part A – essay questions – answer at least 2 from a choice of 5
  • Part B – scenario questions – answer at least 1 from a choice of 2

You must answer four questions in total – and only four questions, no further questions will be marked so you would be wasting your time.

 

Thinking about your exam technique:

  • For the essay questions, look closely at what you are being asked to discuss. For example, if a question has three elements, you must deal with all three to maximise your marks.
  • Use the 15 minutes reading time to read the question carefully and plan out the structure of your answer.
  • Don’t use long paragraphs – no more than 2 or 3 sentences per paragraph. This will help the examiner to easily identify the points you are making.
  • Think about using bullet points to save time and make your answer clear.
    • There is no bullet point format on Exam4 –  but you can make your own by leaving space and using a dash to create one!

 

You can now book for the December 2021 course for Principles of International Taxation, taking advantage of an attractive early bird booking offer!

 

 

3. UK Tax

Saturday was the final revision session for our UK Tax students. Catriona Loughran focussed on the corporate tax elements of the ADIT syllabus. Using a variety of online learning tools, the class worked through ADIT & CTA past papers questions.

 

One challenge in the UK Tax and other jurisdictional papers is extracting the information from the scenario questions. Here are some tips from Catriona:

  • Read the question carefully, several times.
  • Use the 15 minute reading time to actively read the questions, noting down key terms and perhaps drawing out the scenario presented.
  • Think about why you are being given an piece of information, how should it inform your answer?
  • What are you being asked to do? Sometimes the requirements will be broken down into components, guiding you through the answer. At other times, the requirements will be more general – ‘write an email to X advising on‘. With this type of question, you have to work harder to figure out which issues you need to address.
  • Don’t be put off if there is an element of the question that you don’t understand – focus on what you do know!

 

Achieve ADIT Success – UK Tax

Interested in benefitting from our UK Tax expertise? Then sign up for our new online distance learning course, with introductory pricing available until Friday 11 June!

 

The online distance learning course for Module 2.09 includes:

  • Comprehensive e-learning materials written by Catriona Loughran FCA CTA ADIT and other experienced tax professionals.

  • Tutor support from Catriona – contact her directly from an app in the study materials.

  • Mock exam with tailored feedback.

 

 

If you’d like to benefit from our live classes, click here to find out about our online study course for the December 2021 exams.

 

4. US Tax

The final US Tax revision session also took place on Saturday. Ishali Patel worked through past paper questions with her students, including trust taxation, which was last seen on the 2016 exam paper. You should be comfortable with all areas of the syllabus, as you never know which topics will appear in the compulsory questions.

 

If you would like to express your interest in joining us for the next ADIT US Tax exam sitting for Module 2.10 in June 2022, please email us at info@extrataxtraining.com.

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello and let us guide you to ADIT success!

 

Stay Informed

Visit our ADITextra blog to find out what else we’ve covered this semester.

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

With just over two weeks to the exams, there’s no doubt it is ADIT study time!

In the penultimate edition of ADITextra for this semester, we discuss studying for the Principles of International Tax, Transfer Pricing, UK & US Tax modules. 

 

1. Transfer Pricing

The classes for the Transfer Pricing paper finished last weekend. Now it’s time for the students to review what they’ve been learning and attempt more past paper questions to check their understanding.

 

But they’re not alone. Jimmy Ryan is on hand to answer their questions and offer advice on making the most of their remaining ADIT study time. Also, one of our students who passed the Transfer Pricing exam in December has kindly shared her study resources with this semester’s cohort. It’s great to see our ADIT community growing and supporting each other.

 

So what should you be doing with the time remaining?

  • Go over key parts of the OECD Transfer Pricing Guidelines and practice past paper questions to apply them – it’s all about the application of the guidance.
  • Review the case law listed in the ADIT syllabus and make your own summaries.
  • Highlight important words and short phrases in your permitted texts – remember that you won’t have time to read the texts in your exam so you should use them as an aide memoire and be able to find what you need within 10 seconds!

 

You can now book for the December 2021 Transfer Pricing course, with the benefit of an attractive early bird booking offer!

 

2. Principles of International Tax

The Principles of International Taxation students are also maximising their ADIT study time. They are revising key areas of the ADIT syllabus and checking their understanding with Jimmy. They know that, while the classes are over, study support is available right up to the exam.

 

For some of our Principles of International Tax students, this is their first ADIT exam. They have queries about what happens on the day, particularly around using the Exam4 software. We pointed them towards the CIOT guidance and our own article offering advice on sitting online ADIT exams.

 

But there’s nothing like first-hand experience, so we suggested using our learning portal to ask fellow ADIT candidates who sat online exams in December 2020. As usual, our ADIT community didn’t disappoint!

 

Online ADIT Exams

Here’s a snapshot of what they had to say:

  • Make use the CIOT’s ‘ADIT Online Exam Checklist‘ – print it out, fill it out & use it on exam day.
  • Do the full test paper in Exam4 as practice – you don’t want to be using the software for the first time on exam day!
  • Think about how you are going to extract the key information from the scenario questions. You can highlight in the Exam4 software, but you might prefer to include summary facts in your answer or note them on a scrap piece of paper,
  • On the day of your exam, login to Exam4 around an hour before the exam is due to start. This will give you plenty of time for ID verification and enable you to resolve any IT issues before the exam.
  • Have the CIOT’s email address close to hand and contact them immediately if you have any issues – education@adit.org

 

You can now book for the December 2021 course for Principles of International Taxation, taking advantage of an attractive early bird booking offer!

 

 

3. UK Tax

Saturday was our first revision session for our UK Tax students. Catriona Loughran focussed on the personal tax elements of the ADIT syllabus. Using a variety of online learning tools, the class worked through past papers questions and a question on a new topic set by Catriona.

 

Here is a summary of fundamental points to guide you:

  • Know the Statutory Residence Test (including the order to apply it) inside out.
    • As you’re reading the scenario, you should be thinking about which parts of the test may or may not apply.
    • For instance, if the person is retiring, there is no need to discuss the automatic tests for full-time working in the UK or overseas.
    • Equally, you should appreciate the difference between a ‘home’ when considering the Second Automatic UK Test and an ‘accommodation tie’ for the purposes of the Sufficient Ties Test.

 

  • Understand domicile and deemed domicile
    • Know the circumstances where someone will be deemed domiciled in the UK and the implications for Income Tax, Capital Gains Tax and Inheritance Tax.
    • Watch out for ‘trick’ questions. For example, one past paper question asked you to discuss how the non-dom regime applied to an individual. However, in the scenario given, he was actually deemed domiciled through being a Formerly Domiciled Resident. Therefore, the non-dom regime did not apply to him!

 

  • Know why it matters if someone is UK resident and/or domiciled and be able to explain it succinctly in the exam.
    • Remember that being neither UK resident nor domiciled does not mean that there is no liability to UK tax. There may still be UK tax on UK source income or gains (e.g. employment income from working in the UK). If the UK has taxing rights over a non-resident, the question may then require you to consider how a Double Tax Treaty could apply.

 

There are complex areas on the UK Tax syllabus (e.g. offshore trusts). It is necessary to have a full grasp of the fundamentals of residence and domicile to achieve the easier marks in your exam, and provide the building blocks for the more complex topics.

 

ADIT UK Tax

Interested in benefitting from our UK Tax expertise? Then sign up for our new online distance learning course, with introductory pricing available!

 

The online distance learning course for Module 2.09 includes:

  • Tutor support from Catriona – contact her directly from an app in the study materials

  • Mock exam with tailored feedback

 

 

If you’d like to benefit from our live classes, click here to find out about our online study course for the December 2021 exams.

 

4. US Tax

The first US Tax revision session is also taking place this weekend. Ishali Patel is working through past exam papers with her students, discussing the learning points. Similar to the UK paper, understanding the fundamentals, like residence, is key to building a foundation for success.

 

If you would like to express your interest in joining us for the next ADIT US Tax exam sitting for Module 2.10 in June 2022, please email us at info@extrataxtraining.com.

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello and let us help you with your ADIT exam!

 

Stay Informed

Visit our ADITextra blog to find out what else we’ve covered this semester.

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

Have you been attempting the ADIT past papers? If not, it’s time to start!

Each week in ADITextrathe blog for ADIT candidates – we offer you ADIT exam resources for the Principles of International Tax, Transfer Pricing, UK & US Tax modules. 

 

1. Transfer Pricing

This weekend sees the second and final  intensive revision session for the Transfer Pricing paper. Jimmy Ryan is recapping on key topics, discussing ADIT past papers and giving last minute tips on presenting knowledge to the examiner.

 

You will find five sets of ADIT past papers for the Transfer Pricing module available on the CIOT website, along with suggested solutions and candidate scripts:

 

As a minimum, you should work through the questions on each of these papers before your exam, sitting at least one paper in full as a mock exam.

 

You can now book for the December 2021 Transfer Pricing course, with the benefit of an attractive early bird booking offer!

 

2. Principles of International Tax

It’s also intensive revision time for the Principles of International Taxation students. They are working through past paper questions with Jimmy, improving their approach to answering the essay questions in Part A and dealing with the scenario questions in Part B.

 

In particular with the Principles of International Tax syllabus, there is a lot of material to read to prepare for the paper. But the exam does not test your reading skills; it tests your writing skills and the application of the knowledge you have acquired through reading. There comes a time (and it’s probably already here) when you have to stop reading and start writing. Yes, you’ve heard it here before, there is no better way to learn than attempting questions from ADIT past papers!

 

You can now book for the December 2021 course for Principles of International Taxation, taking advantage of an attractive early bird booking offer!

 

 

3. UK Tax

This week was mock exam time for our UK Tax students. Catriona Loughran set the mock paper using a mixture of ADIT past papers, adapted CTA questions and her own questions for newer topics.

 

New topics on the syllabus are one area where ADIT past papers can’t help you. You should be aware of what has been added to the syllabus in the last year or two – and be prepared to see them on your exam paper. Two new UK areas to think about for this year are:

  • Digital Services Tax
  • Profit Fragmentation anti-avoidance legislation

 

So how can you prepare when past paper questions aren’t available? We recommend preparing a briefing note on new topics – an overview of the rules that you could write in 30 minutes in the exam.

 

ADIT UK Tax

Interested in benefitting from our UK Tax expertise? Then sign up for our new online distance learning course, with introductory pricing available!

 

The online distance learning course for Module 2.09 includes:

  • Tutor support from Catriona – contact her directly from an app in the study materials

  • Mock exam with tailored feedback

 

 

If you’d like to benefit from our live classes, click here to find out about our online study course for the December 2021 exams.

 

4. US Tax

Robert Misey returned this week to guest lecture on Cross-Border Merges & Acquisitions, offering another engaging session to our US Tax students. Afterwards, it was time for Ishali Patel to complete the tuition classes by covering Subpart F of the US CFC rules.

 

And so, on to the mock exam which the students are sitting this weekend. There is one thing for sure about our ADIT candidates, they’re dedicated to their studies!

 

If you would like to express your interest in joining us for the next ADIT US Tax exam sitting for Module 2.10 in June 2022, please email us at info@extrataxtraining.com.

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello and let us help you with your ADIT exam!

 

Stay Informed

Visit our ADITextra blog to find out what else we’ve covered this semester.

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

At Extratax Training, we’re here to support you with guidance for your ADIT exam.

Each week in ADITextrathe blog for ADIT candidates – we offer you ADIT exam resources for the Principles of International Tax, Transfer Pricing, UK & US Tax modules. 

 

1. Transfer Pricing

The transfer pricing tuition classes ended last week and the students have now completed their mock exam. This weekend is the first of the intensive revision sessions, focussing on past paper questions. Jimmy Ryan is sharing his expertise on how to present knowledge to the examiner.

 

You can now book for the December 2021 Transfer Pricing course, with the benefit of an attractive early bird booking offer!

 

2. Principles of International Tax

It’s also intensive revision time for the Principles of International Taxation students. They are working through past paper questions with Jimmy, thinking about how to structure their answers to the essay questions in Part A and approach the scenario questions in Part B.

 

The individual feedback from the mock exam is an invaluable tool in improving their exam performance. If there is a time to fail, it’s in the mock exam. It is more important to attempt a mock than to pass it.

 

You’ll learn so much by sitting down under ADIT exam conditions for 3 hours & 15 minutes and completing a full past paper:

  • How much are you able to type in the allotted time?
  • Did you stick to the timings and complete all of the questions?
  • How did you feel in the last hour of the exam versus the first hour?
  • How did you choose which questions to answer?
  • With hindsight, did you choose the best ones for you?
  • Did you panic when you encountered something unfamiliar in a question?
  • How do your answers compare to the suggested solutions?

 

Particularly if you are sitting your first ADIT exam, the exam day should not be your first experience of attempting a full paper. The best time to find out the answers to the questions above is in the weeks leading up to the exam, when you have time to learn from it and improve your exam technique.

 

You can now book for the December 2021 course for Principles of International Taxation, taking advantage of an attractive early bird booking offer!

 

 

3. UK Tax

Friday was the final tuition class for our UK Tax students. Catriona Loughran covered a range of topics from the Module 2.09 syllabus:

  • Globally mobile employees

  • Transfer of Assets Abroad anti-avoidance rules

  • Profit fragmentation anti-avoidance rules – newly introduced in 2019 so highly examinable

  • Stamp duty, including the new non-resident surcharge

  • VAT

  • Customs Duties

 

ADIT Exam – UK Tax

Interested in benefitting from our UK Tax expertise? Then sign up for our new online distance learning course, with introductory pricing available!

 

The online distance learning course for Module 2.09 includes:

  • Tutor support from Catriona – contact her directly from an app in the study materials

  • Mock exam with tailored feedback

 

 

If you’d like to benefit from our live classes, click here to find out about our online study course for the December 2021 exams.

 

4. US Tax

Robert Misey joined us as a guest lecturer on the US Tax course this week to share his expertise on US Transfer Pricing. Rob is a US tax attorney focusing on international taxation, M&A structures, transfer pricing strategies, and inbound and outbound planning for multinationals. He’s also an author of an essential reading book from the syllabus – Schadewald, M. and Misey, R. ‘Practical Guide to US Taxation of International Transactions’.

 

Catriona was delighted to introduce Rob to the US Tax students and join the class to learn from his knowledge. Rob used practical examples throughout the class to demonstrate the application of the US Transfer Pricing rules. Undoubtedly, he would win the award for most inventive use of hockey pucks in a transfer pricing discussion!

 

Rob’s enthusiasm for transfer pricing shone through and we can’t wait to welcome him back to next week’s guest lecture on Cross-Border Merges & Acquisitions.

 

If you would like to express your interest in joining us for the next ADIT US Tax exam sitting for Module 2.10 in June 2022, please email us at info@extrataxtraining.com.

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello and let us help you with your ADIT exam!

 

Stay Informed

Visit our ADITextra blog to find out what else we’ve covered this semester.

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

At Extratax Training, we’re here to support you with guidance for your ADIT exams.

Each week in ADITextrathe blog for ADIT candidates – we discuss the topics covered in our online ADIT courses and share free video content. Find ADIT exam resources for Principles of International Tax, Transfer Pricing, UK & US Tax classes. 

Read on to find out about the topics covered in this week’s online classes. The spotlight is on Principles of International Taxation and you can watch a discussion on Thin Capitalisation. If you missed any earlier editions of ADITextra, you’ll find them here.

 

1. Transfer Pricing

In the final transfer pricing tuition class of the semester, James (Jimmy) Ryan discussed:

  • E-commerce

  • Public Affairs 

  • Business Decisions

  • Management Incentives

  • Customs Duties

 

Having completed the tuition element of the course, our students are now sitting their mock exam. The feedback and guidance from Jimmy on their mock exam papers will be invaluable.

 

You can now book for the December 2021 Transfer Pricing course, with the benefit of an attractive early bird booking offer!

 

2. Principles of International Tax

Wednesday saw the final Principles of International Taxation tuition class, with Jimmy looking at:

  • Thin Capitalisation

  • Taxation and International Human Rights Instruments

  • Indirect Taxes and International Taxation

  • Cross-Border Mergers

 

You can watch part of the discussion on Thin Cap in the Spotlight section below.

 

It’s also mock exam time for the Principles of International Taxation students. If you regularly read this blog, you’ll know how often we stress the importance of attempting past paper questions. At this stage, you should be working on them under exam conditions, sticking to the time you’ll have in the exam. You should type all of your answers to get a realistic idea of how much you can write in the time allowed.

 

You can now book for the December 2021 course for Principles of International Taxation, taking advantage of an attractive early bird booking offer!

 

 

3. UK Tax

On Thursday, we had a guest lecturer to share her expertise of Inheritance Tax (IHT) and trusts, including offshore trusts. This is a complex area, particularly challenging if your background is in corporate tax or you’re unfamiliar with the UK tax system.

 

To successfully answer a question on this topic in your exam, you should know the answers to these questions:

  • What is IHT and when does it apply?

  • How does domicile and deemed domicile status impact on UK IHT?

  • What is the spousal exemption, and how does it apply where one party is UK domiciled and the other is non-dom?

  • How do the Gifts with Reservation of Benefits rules operate?

  • What are the tax implications on setting up, running and making distributions from a trust?

  • What happens if a trust is ‘settlor-interested’?

  • How relevant anti-avoidance provisions, e.g. transfer of asses abroad, apply?

  • What are the benefits of offshore trusts?

 

ADIT Guidance – UK Tax

Interested in benefitting from our UK Tax expertise? Then sign up for our new online distance learning course, with introductory pricing available!

 

The online distance learning course for Module 2.09 includes:

  • Tutor support from Catriona – contact her directly from an app in the study materials

  • Mock exam with tailored feedback

 

 

If you’d like to benefit from our live classes, click here to find out about our online study course for the December 2021 exams.

 

4. US Tax

Ishali Patel returned on Thursday for the US Tax course looking at:

  • Federal Estate Tax:

    • Domicile of individuals

    • Situs of assets

    • Transfers to non-resident alien beneficiaries

    • Relief of double taxation: estate tax treaties

  • Federal Gift Tax:

    • US persons and non-resident aliens

    • Situs of assets for gift tax purposes

    • Transfers to non-resident aliens

  • Foreign Trusts:

    • Grantor trust rules

    • Non-grantor trusts and accumulated income

       

We’re excited about Robert Misey joining us as a guest lecturer on the US Tax course for the next two weeks. Rob is a US tax attorney focusing on international taxation, M&A structures, transfer pricing strategies, and inbound and outbound planning for multinationals. He’s also an author of an essential reading book from the syllabus – Schadewald, M. and Misey, R. ‘Practical Guide to US Taxation of International Transactions’.

 

If you would like to express your interest in joining us for the next ADIT US Tax exam sitting for Module 2.10 in June 2022, please email us at info@extrataxtraining.com.

 

5. Spotlight on Thin Capitalisation

Each week, we put the spotlight on a topic covered in one of our classes and offer you ADIT guidance. This time, let’s look at Thin Capitalisation. The video was taken from this week’s Principles of International Taxation class, but it’s equally relevant for the Transfer Pricing paper.

 

Watch & Learn

Watch part of this week’s Principles of International Taxation course for an overview of  ‘Thin Capitalisation‘.

 

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello and let us offer you our ADIT guidance!

 

Stay Informed

Visit our ADITextra blog to find out what else we’ve covered this semester.

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

There’s not long to go until the June exams, so you should be getting ready to move into your revision phase and gathering your ADIT exam resources.

Each week in ADITextrathe blog for ADIT candidates – we discuss the topics covered in our online ADIT courses and share free video content. Find ADIT exam resources for Principles of International Tax, Transfer Pricing, UK & US Tax classes. 

Read on to find out about the topics covered in this week’s online classes. The spotlight is on Transfer Pricing and you can watch a discussion on Intangibles. If you missed any earlier editions of ADITextra, you’ll find them here.

 

1. Transfer Pricing

In Tuesday’s transfer pricing class, James (Jimmy) Ryan focussed on specific transactions, discussing intangible property and business restructuring.

 

Jimmy looked at the four sections in Chapter VI of the OECD Transfer Pricing Guidelines covering ‘Special Considerations for Intangibles’:

  • identifying intangibles (see the Spotlight section below)

  • ownership of intangibles and transactions involving the development, enhancement, maintenance, protection and exploitation (DEMPE) of intangibles

  • transactions involving the use or transfer of intangibles

  • supplemental guidance for determining the arm’s length conditions in cases involving intangibles

 

As part of preparing your ADIT exam resources, you should read through and highlight Chapter VI in the OECD TPG. You should also take note of the Annex to Chapter VI, which contains 29 examples illustrating the guidance on intangibles.

 

Jimmy moved on to Chapter IX of the Transfer Pricing Guidelines on Business Restructuring. He discussed typical business models implemented in a restructuring, the OECD’s approach to business restructuring and how tax authorities respond to business restructuring.

 

If you would like to express your interest in joining us for the December 2021 Transfer Pricing course, please use the contact form below or email info@extrataxtraining.com. We’ll shortly be launching the December 2021 courses with an attractive early bird booking offer!

 

2. Principles of International Tax

The Principles of International Taxation class spent last week & this week on Transfer Pricing, an important area of the Module 1 syllabus. Some of the students have already passed, or are currently studying for, the Transfer Pricing module so have no shortage of knowledge. If you are experienced in Transfer Pricing, the challenge for you in answering questions on the Principles of International Tax paper is understanding the level of detail required by the examiner. As always, two points are key:

  • Get to grips with what is required by attempting past paper questions under exam conditions and then comparing your answer to the suggested solutions.
  • Stick rigidly to your time allocation in the exam – don’t be tempted to spend longer on a question because you’re comfortable with the topic.

 

Other students on the Principles of International Tax course are new to Transfer Pricing, so Jimmy’s ability to explain the foundations is invaluable. If you missed it, check out his video on the Fundamentals of Transfer Pricing on our YouTube channel.

 

This week’s class covered:

  • Intangibles 

  • Cost Contribution Arrangements

  • Intra-Group Services

  • Business Restructuring

  • Transfer Pricing Documentation

 

You can watch part of the discussion on Special Considerations for Intangibles in the Spotlight section below.

 

If you are interested in joining us for the December 2021 course for Principles of International Taxation, please use the contact form below or email info@extrataxtraining.com. In early May, we will launch the December 2021 courses with an attractive early bird booking offer!

 

 

3. UK Tax

On Thursday, the UK Tax class looked at the remittance basis of taxation for UK resident but non-domiciled individuals. This is an important part of the Module 2.09 syllabus. When it comes to domicile and remittance, our ADIT students benefit from the expertise of James Heathcote, a Spear’s Top Recommended Tax & Trusts Accountant who authored the study materials on remittance. He uses his expertise to bring this complex topic to life with helpful illustrations.

 

To successfully answer a question on remittance to the UK in your exam, you should know the answers to these questions:

  • What is a remittance?

  • What are the exceptions?

  • What is a mixed fund?

  • What are the ordering rules for remittance from a mixed fund?

  • What was the opportunity for mixed fund cleansing?

 

ADIT Exam Resources – UK Tax

Interested in benefitting from our UK Tax expertise? Then sign up for our new online distance learning course, with introductory pricing available!

 

The online distance learning course for Module 2.09 includes:

  • Tutor support from Catriona – contact her directly from an app in the study materials

  • Mock exam with tailored feedback

 

 

4. US Tax

Ishali Patel returned on Thursday for the US Tax course looking at:

  • Foreign Account Tax & Compliance Act (FATCA)

  • Foreign Bank Account Reports & entity information reporting

  • Exchange of information

  • Co-operation between revenue authorities

 

We’re excited about Robert Misey joining us as a guest lecturer on the US Tax course later this semester. Robert is a US tax attorney focusing on international taxation, M&A structures, transfer pricing strategies, and inbound and outbound planning for multinationals. He’s also an author of an essential reading book from the syllabus – Schadewald, M. and Misey, R. ‘Practical Guide to US Taxation of International Transactions’.

 

If you would like to express your interest in joining us for the next ADIT US Tax exam sitting for Module 2.10 in June 2022, please use the contact form below or email info@extrataxtraining.com.

 

5. Spotlight on Transfer Pricing of Intangibles

Each week, we put the spotlight on a topic covered in one of our classes and offer you free ADIT exam resources. This time, let’s look at Transfer Pricing of Intangibles. The video was taken from this week’s Principles of International Taxation class, but it’s equally relevant for the Transfer Pricing paper.

 

Watch & Learn

Watch part of this week’s Principles of International Taxation course for an overview of  ‘Transfer Pricing of Intangibles‘.

 

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello and let us welcome you to our ADIT community!

 

Stay Informed

Visit our ADITextra blog to find out what else we’ve covered this semester.

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

With little over 7 weeks to go to the June exams, what is your ADIT study plan? If you don’t have one or haven’t been sticking to it, now is the time to re-focus and decide how you’ll go about achieving your ADIT goal.

Each week in ADITextrathe blog for ADIT candidates – we discuss the topics covered in our online ADIT courses and share free video content. Follow along with Principles of International Tax, Transfer Pricing, UK & US Tax as a guide for your ADIT study plan. 

Read on to find out about the topics covered in this week’s online classes. To mark the launch of our distance learning course, the spotlight is on UK Tax and you can watch a discussion on International Financing. If you missed any earlier editions of ADITextra, you’ll find them here.

 

1. Transfer Pricing

The transfer pricing class returned on Tuesday after a fortnight’s break. Well, we say break, but the students had been studying and sitting their first mock exam. With the limited time remaining before Thursday 10 June, you should be getting in the swing of attempting past paper questions. Here’s some great advice that James (Jimmy) Ryan gave his transfer students this week as he set a past paper for the weekly assignment:

 

As a minimum, I would like you at attempt question 8….but in truth, I would really like you to spend time, under exam time constraints, to answer more than 1 question. The time spent now attempting questions, putting yourself under pressure to answer these question under time constraints will expose you to what you are comfortable with and, more importantly, what you are not. You will learn much more quickly and effectively by submitting an answer that you are not happy with as you will be annoyed with yourself for not including some parts and it will be seared into your minds for the big day in June!

 

At this stage, the course has almost covered the full transfer pricing syllabus, with this week’s class looking at:

  • Transfer pricing documentation:

    • Local File

    • Master File

    • Country by Country Reporting

  • Safe Harbours

  • Dispute Resolution

    • Corresponding Adjustments

    • Mutual Agreement Procedure (MAP)

    • Arbitration

    • Advanced Pricing Agreements (APA)

 

Don’t forget to include these compliance areas in your ADIT study plan!

 

If you would like to express your interest in joining us for the December 2021 Transfer Pricing course, please use the contact form below or email info@extrataxtraining.com. We’ll shortly be launching the December 2021 courses with an attractive early bird booking offer!

 

2. Principles of International Tax

The Principles of International Taxation class also returned after an Easter break. Jimmy is spending this week & next on Transfer Pricing, an important area of the Module 1 syllabus. As you would probably guess, it’s one of his favourite topics and his enthusiasm for the subject shines through!

 

Transfer pricing is new to some of our Principles of International Tax students, so Jimmy’s ability to explain the foundations is invaluable. If you missed it, check out his video on the Fundamentals of Transfer Pricing on our YouTube channel.

 

This week’s class covered:

  • Introduction to Transfer Pricing

  • Article 9 of the OECD Model Tax Convention

  • OECD Transfer Pricing Guidelines

  • Advanced Pricing Agreements (APA)

  • Transfer Pricing Case Law, including:

    • DSG Retail v HMRC

    • GE Capital Canada v The Queen

    • SNF v Commissioner of Taxation

    • State Aid cases

 

When preparing your ADIT study plan, think about any tax cases that you will be expected to know. For some papers, the syllabus lists specific cases. However, for Principles of International Tax, the guidance on cases is more general:

 

The syllabus does not examine the rules of any one state. Decisions of the courts of many countries are therefore relevant to this subject. Leading cases are drawn from as far afield as New Zealand, South Africa, Canada, France and Germany.

Cases from the non-English speaking world are generally from the Bundesfinanzhof (German Federal Tax Court), the Conseil d’Etat (French Supreme Administrative Court) or the Hoge Raad (Netherlands Supreme Court). The more important cases are summarised in European Taxation or the Bulletin for International Taxation.

 

If you’re undertaking self-study, this puts the onus on you to compile a list of relevant cases and learn about them. Remember to keep up-to-date, as you’re expected to have knowledge of any court case reported up to six months before the exam. Plus there can be additional credit available for knowledge of more recent developments. A great way of staying updated is to sign up for the International Tax newsletter from MNE Tax.

 

If you are interested in joining us for the December 2021 course for Principles of International Taxation, please use the contact form below or email info@extrataxtraining.com. In early May, we will launch the December 2021 courses with an attractive early bird booking offer!

 

 

3. UK Tax

On Thursday, the UK Tax class looked at the final Corporate Tax topics on the syllabus, under the heading of ‘International Financing’. See the Spotlight section below to learn more.

 

Now that all the Corporate Tax topics have been covered, the students can throw themselves into practising past paper questions. Many of the exam questions cover more than one part of the syllabus, so it’s important to understand how the various pieces of legislation interact and – we can’t stress this enough – attempt questions under exam conditions.

 

ADIT UK Tax – Online Distance Learning Course

Interested in benefitting from our UK Tax expertise? Then sign up for our new online distance learning course, with introductory pricing available!

 

The online distance learning course for Module 2.09 includes:

  • Tutor support from Catriona – contact her directly from an app in the study materials

  • Mock exam with tailored feedback

 

 

4. US Tax

It is already Week 6 of our US Taxation course, with Ishali Patel returning on Thursday to discuss:

  • Foreign investment in US real property interests

  • The OECD and US Model tax treaties

  • Limitations of benefits provisions

  • Provisions relating to hybrid entities

 

The Limitation of Benefits (LOB) clause in US tax treaties is a challenge to understand. If you’re not familiar with it, give yourself enough time in your ADIT study plan to get to grips with it.

We’re very excited to announce that Robert Misey is joining us as a guest lecturer on the US Tax course later this semester. Robert is a US tax attorney focusing on international taxation, M&A structures, transfer pricing strategies, and inbound and outbound planning for multinationals. He’s also an author of an essential reading book from the syllabus – Schadewald, M. and Misey, R. ‘Practical Guide to US Taxation of International Transactions’.

 

If you would like to express your interest in joining us for the next ADIT US Tax exam sitting for Module 2.10 in June 2022, please use the contact form below or email info@extrataxtraining.com.

 

5. Spotlight on International Financing

Each week, we put the spotlight on a topic covered in one of our classes and offer you free ADIT content. This time, let’s look at UK provisions relating to International Financing.

 

If you get an exam question involving loans or other financing transactions, you should be thinking about the following areas of the UK syllabus:

  • Transfer pricing / thin capitalisation
  • Unallowable purpose under s441 & s442 CTA 2009
  • Reporting requirements for international movements of capital
  • Late paid interest
  • Corporate Interest Restriction (CIR)
  • Hybrid mismatch – although this legislation is wider than financing costs, and applies to any payments meeting the conditions.

 

You should check out the judgment in the Blackrock case for a discussion on transfer pricing of loans and unallowable purpose.

 

When looking at the Corporate Interest Restriction, remember that it is a mechanical test, working through a series of calculations. The main challenge in understanding it can be getting past the long list of acronyms used in the legislation & HMRC guidance. Don’t let them confuse you or put you off – ignore most of the names & focus on the principles. Take your time to work through the key steps, practising lots of questions of course!

 

Watch & Learn

Watch part of this week’s UK Tax course for an overview of  ‘International Financing‘.

 

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello and let us welcome you to our ADIT community!

 

Stay Informed

Visit our ADITextra blog to find out what else we’ve covered this semester.

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

Free ADIT content to help you pass your June 2021 exams. For easy access to all our free international tax content, subscribe to our YouTube channel

Each week in ADITextrathe blog for ADIT candidates – we discuss the topics covered in our online ADIT courses and share free video content from our live classes. Follow along with Principles of International Tax, Transfer Pricing, UK & US Tax to guide your self-study. 

Read on for a summary of our free ADIT content. In addition, watch our founder explain the new UK Digital Services Tax.

 

1. Transfer Pricing

While we’re taking a fortnight’s break from the live transfer pricing classes, take the opportunity to check out our free video content on key topics from the ADIT Transfer Pricing syllabus:

 

We’re no longer accepting bookings for this semester’s Transfer Pricing course. If you would like to express your interest in joining us for the December 2021 course, please use the contact form below or email info@extrataxtraining.com. We’ll shortly be launching the December 2021 courses with an attractive early bird booking offer!

 

2. Principles of International Tax

The Principles of International Taxation classes are also on an Easter break, with the students using the time to consolidate their knowledge and tackle their first mock exam. If you missed them in previous editions of ADITextra, watch free videos from the Principles of International Tax course discussing:

 

Controlled Foreign Company (CFC) anti-avoidance rules are part of the Principles of International Tax syllabus. You should have an awareness about the types of CFC legislation implemented by OECD states. So you should check out last week’s edition of ADITextra to watch an overview of the Controlled Foreign Company rules in the United States.

 

We’re no longer accepting bookings for this semester’s Principles of International Taxation course. If you would like to express your interest in joining us for the December 2021 course, please use the contact form below or email info@extrataxtraining.com. Soon, we will launch the December 2021 courses with an attractive early bird booking offer!

 

 

3. UK Tax

On Thursday, the UK tax course returned after a two week break. For the first hour, Catriona Loughran led the discussion on the UK’s Digital Services Tax – see the Spotlight section below for free content from the class.

 

Next, it was time to learn about a key topic from the ADIT UK syllabus – Controlled Foreign Company (CFC) rules. This is a popular area for an exam question. You should understand how the legislation works and be able to apply it to the scenario given in the question. Getting to grips with the UK CFC rules is not straightforward – the gateway tests can be confusing and you may find yourself lost in the complexities.

 

As always, don’t spend too much time reading about the topic. Once you think you understand it, start practising questions, working your way up to past paper questions. It’s the application of your knowledge that matters for the exam, so making yourself type out full answers to past paper questions is the best preparation!

 

UK Tax – Free ADIT Content

If you missed them in previous editions of ADITextra, watch free content from the United Kingdom Taxation course covering:

 

ADIT UK Tax – Online Distance Learning Course

Although we’re no longer accepting bookings for this semester’s UK Tax course, you can still benefit from our expertise by signing up for our new online distance learning course.

 

The online distance learning course for Module 2.09 includes:

  • Tutor support from Catriona – contact her directly from an app in the study materials
  • Mock exam with tailored feedback

 

 

4. US Tax

In Thursday’s US Taxation course, Ishali Patel shared her international tax expertise, discussing:

  • Related party financing of a US subsidiary: anti-earnings stripping rules & debt versus equity

  • Anti-conduit rules

  • Distributions from a US subsidiary

  • Investment in foreign partnerships and funds

  • Distributions from foreign subsidiaries

  • Corporate transfers to foreign subsidiaries

 

US Tax – Free ADIT Content

If you missed them in previous editions of ADITextra, watch free content from the United States Taxation course discussing:

 

We’re no longer accepting bookings for this semester’s United States Taxation course. If you would like to express your interest in joining us for the next ADIT exam sitting for Module 2.10 in June 2022, please use the contact form below or email info@extrataxtraining.com.

 

5. Spotlight on UK Digital Services Tax (DST)

Each week, we put the spotlight on a topic covered in one of our classes and offer you free ADIT content. This time, let’s look at the UK Digital Services Tax, introduced by Finance Act 2020. While this was discussed in this week’s UK Tax course, it’s also of interest for the Principles of International Taxation module due to the OECD’s work in this area.

 

The UK’s Digital Services Tax legislation is contained in Part 2 of, and Schedules 8 to 10 to, the Finance Act 2020. It applies to revenue earned in connection with digital services activities from 1 April 2020.

 

DST is a tax on UK revenues (not profits) of digital businesses that provide one or more of the following three digital services activities:

  • a social media service;
  • an internet search engine; and / or
  • an online marketplace.

 

Where the revenues received in connection with the digital services activities, attributable to UK users, exceed annual thresholds, the group must submit DST returns and may have to pay DST.

 

The annual revenue thresholds applying to a group are:

  • £500m of worldwide revenue from the digital services activities; with
  • £25m of these revenues attributable to UK users.

 

DST applies at a rate of 2% on UK digital services revenues above an annual allowance of £25m; unless the group elects to calculate their liability on the Alternative Basis of Charge provision.

 

The DST legislation is new and complex. We’re grateful to Sarah Blakelock, who wrote the learning materials for this topic. Her clear explanations on how the legislation operates, along with helpful illustrations, provide our students with everything they need to successfully answer a DST question.

 

Watch & Learn

Watch part of this week’s UK Tax course for an overview of  ‘Digital Services Tax‘.

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello and let us welcome you to our ADIT community!

 

Stay Informed

Visit our ADITextra blog to find out what else we’ve covered this semester.

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

Studying for the Advanced Diploma in International Tax qualification is an excellent way to learn the fundamentals of international taxation. Read ADITextrathe blog for ADIT – to find out more!

Whether you are new to international tax or an experienced professional wishing to showcase your expertise, the ADIT certification offers you the opportunity to stand out from the crowd.

Read on to discover how online study programmes from Extratax Training guide you to success. The spotlight for this edition of ADITextra is the US Controlled Foreign Companies rules.

 

1. Transfer Pricing

While we’re taking a fortnight’s break from the live transfer pricing classes, take the opportunity to check out our free video content on key topics from the ADIT Transfer Pricing syllabus:

 

We’re no longer accepting bookings for this semester’s Transfer Pricing course. If you would like to express your interest in joining us for the June 2022 course, please use the contact form below or email info@extrataxtraining.com. We’ll shortly be launching the June 2022 courses with an attractive early bird booking offer!

 

2. Principles of International Tax

The Principles of International Taxation classes are also on an Easter break, with the students using the time to consolidate their knowledge and tackle their first mock exam. If you missed them in previous editions of ADITextra, watch free videos from the Principles of International Tax course discussing:

 

Controlled Foreign Company (CFC) anti-avoidance rules are part of the Principles of International Tax syllabus. You should have an awareness about the types of CFC legislation implemented by OECD states. So you should check out this week’s spotlight section below, giving you an overview of the Controlled Foreign Company rules in the United States.

 

Fundamentals – Principles of International Taxation

The Principles of International Tax syllabus provides you with the fundamentals of international taxation – a reason why many ADIT candidates choose to study it first, before moving on to a thematic or jurisdiction module.

 

We’re no longer accepting bookings for this semester’s Principles of International Taxation course. If you would like to express your interest in joining us for the June2022 course, please use the contact form below or email info@extrataxtraining.com. We’ll shortly be launching the June 2022 courses with an attractive early bird booking offer!

 

 

3. UK Tax

The UK tax course is currently on a two week break. This gives the students time to review what they’ve learnt so far, revisit any challenging areas and work on past exam questions. Plus some relaxation time, of course!

 

ADIT UK Tax – Distance Learning Course

Although we’re no longer accepting bookings for this semester’s United Kingdom Advanced International Tax course, you can still benefit from our expertise. We have compiled a comprehensive set of online study materials for the ADIT UK paper. We’ve just launched a limited edition beta-testing version of these materials as part of our distance learning course.

 

The UK distance learning course was written by Catriona Loughran FCA CTA ADIT and other experienced tax professionals, including:

 

If you are interested in joining the distance learning course for the June 2022 exam, please email info@extrataxtraining.com.

 

4. US Tax

In Thursday’s US Taxation course, Ishali Patel shared her international tax expertise, discussing:

  • US company expanding operations globally

  • Foreign branches

  • Controlled Foreign Corporations (CFCs)

  • Global Intangible Low-Taxed Income (GILTI)

  • Passive Foreign Investment Companies (PFICs)

  • Foreign Derived Intangible Income (FDII)

  • Participation exemption

 

Check out the Spotlight section below for a discussion on the CFC rules.

 

Fundamentals of International Taxation – United States

As you can see from the list of topics above, to the uninitiated, US tax can seem like a confusing maze of acronyms! Ishali’s deep understanding of US tax, along with her enthusiasm for sharing her knowledge, means she can guide you through the maze to conquer the fundamentals of US international tax.

 

We’re no longer accepting bookings for this semester’s United States Taxation course. If you would like to express your interest in joining us for the next ADIT exam sitting for Module 2.10 in June 2022, please use the contact form below or email info@extrataxtraining.com.

 

5. Spotlight on United States Tax

Each week, we’ll put the spotlight on a topic covered in one of our classes. This time, let’s look at the US Controlled Foreign Corporations rules. While this was discussed in this week’s US Tax course, it’s also relevant for the Principles of  International Taxation module.

 

A foreign corporation is a CFC if US shareholders own:

  • more than 50% off the combined voting power of all classes of shares, or
  • more than 50% of the total value of the foreign corporation.

 

A US shareholder is any US person owning at least 10% of the value off the foreign corporation.

 

There are two anti-deferral systems in place to prevent CFC’s sheltering income from US tax:

  • Subpart F income, and
  • Globally Intangible Low-Taxed Income (GILTI).

 

Watch & Learn

Watch part of this week’s US Tax course for an overview of  ‘Controlled Foreign Corporations‘.

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello and let us welcome you to our ADIT community!

 

Stay Informed

Visit our ADITextra blog to find out what else we’ve covered this semester.

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

ADITextrathe blog for ADIT International Tax. Choosing the right international tax course for you is key to your success.

ADITextra tells you more about Extratax Training’s online international tax courses to help you make this important decision.

Read on to learn about the topics covered in this week’s online classes. The spotlight for this edition of ADITextra is on Principles of International Taxation.

 

1. Transfer Pricing

In Tuesday’s session, James (Jimmy) Ryan started the class by looking at recharacterisation issues. Tax authorities can recharacterise a transaction when they feel it should be disregarded, setting aside the contractual terms of a transaction. A tax authority can do this in one of two ways:

  • Disregard the actual transaction; or
  • Impose another transaction which is closer in substance to what independent entities would have entered into.

Tax authorities typically use domestic anti-avoidance legislation to achieve this outcome, for example, a GAAR (General Anti-Avoidance Rule).

 

Jimmy moved on to discuss Permanent Establishments in the context of transfer pricing. Firstly considering the creation of a Permanent Establishment, then the attribution of profits to a PE. In answering PE questions in your exam, you should be comfortable discussing case law on PEs, including:

 

Online Transfer Pricing Course

If you regularly read ADITextra, you’ll have heard us talking about the importance of practising past paper questions. There are no Transfer Pricing classes for the next two weeks, so it’s the perfect time for our students to consolidate their knowledge and work on their exam technique.

 

Jimmy had planned to release a ‘test’ mock exam for completion over the break, before the full mock takes place at the beginning of May. But then he mentioned to the students that he’s always happy to give them more exam-style questions. And guess what? He’d barely finished speaking before the students said yes, great idea, please give us two mock papers to do! It’s fantastic to see such dedication and enthusiasm from our students.

 

We’re no longer accepting bookings for this semester’s Transfer Pricing course. If you would like to express your interest in joining us for the December 2021 course, please use the contact form below or email info@extrataxtraining.com.

 

 

2. Principles of International Tax

In Wednesday’s Principles of International Tax course, Jimmy discussed the following key topics from the ADIT syllabus:

  • Entity characterisation

  • Hybrid entities and hybrid mismatches

  • Tax havens and harmful tax competition

  • Controlled foreign company (CFC) anti-avoidance legislation

 

Check out the Spotlight section below to learn more about entity classification.

 

Online Principles of International Tax Course

One of the benefits of joining live classes in small groups is asking questions and chatting with the tutor & other students. In this week’s class, the lively discussion covered a range of topics including digital services tax, withholding taxes, work of the OECD on the digital economy and double taxation.

 

We’re no longer accepting bookings for this semester’s Principles of International Taxation course. If you would like to express your interest in joining us for the December 2021 course, please use the contact form below or email info@extrataxtraining.com.

 

 

3. UK Tax

The UK tax course is currently on a two week break. This gives the students time to review what they’ve learnt so far, revisit any challenging areas and work on past exam questions. Plus some relaxation time, of course!

 

ADIT UK Tax – Distance Learning Course

Although we’re no longer accepting bookings for this semester’s United Kingdom Advanced International Tax course, you can still benefit from our expertise. We have compiled a comprehensive set of online study materials for the ADIT UK paper. We’re launching a limited edition beta-testing version of these materials as part of our distance learning course this week.

 

The UK distance learning course was written by Catriona Loughran FCA CTA ADIT and other experienced tax professionals, including:

 

If you are interested in joining the distance learning course for the June 2021 exam, please email info@extrataxtraining.com.

 

4. US Tax

In Thursday’s US Taxation course, Ishali Patel shared her international tax expertise, discussing:

  • Whether a US trade or business exists

  • Safe harbours for US investment activity

  • Permanent Establishment

  • Effectively connected income

  • US branch taxes

 

US International Tax Course

It’s great to see students from across the world coming together to learn about US tax. A minority work in US tax, the rest of them have chosen the US tax module because of its importance in the global business environment.

 

We’re no longer accepting bookings for this semester’s United States Taxation course. If you would like to express your interest in joining us for the next ADIT exam sitting for Module 2.10 in June 2022, please use the contact form below or email info@extrataxtraining.com.

 

5. Spotlight on Principles of International Tax

Each week, we’ll put the spotlight on a topic covered in one of our classes. This time, let’s look at entity classification. While this was discussed in this week’s Principles of International Tax course, it’s equally relevant for the UK Tax module.

 

Private International Law is a branch of law dealing with a state’s domestic recognition of overseas law, and how the courts interpret overseas legislation in a domestic context. How do domestic courts recognise overseas entities and payments? A number of questions have been developed by UK law to help the courts determine the nature of the entity and the payment being made:

  • What kind of entity is it under the foreign law?
  • What kind of payment is it under the foreign law?
  • Given the answer to these questions, what is the tax treatment in the UK?

 

The key case law is the UK Court of Appeal’s decision in Memec plc v HMRC. For your exam, you should know the tests set out in the Memec case for determining whether an entity is transparent or opaque for UK tax purposes:

  1. Does the entity have a separate legal identity?

  2. Has the entity issued share capital (or something analogous to share capital)?

  3. Is the business carried on by the entity or by its members?

  4. Are the members of the entity entitled to a share of the profits as they arise or only when the it distributes the profits to its members?

  5. Who is responsible for debts incurred by the business?

  6. Does the entity beneficially own its assets or do the members?

 

You should be able to apply these tests to a scenario given in the exam, discussing whether an entity is likely to be considered as transparent or opaque.

 

Watch & Learn

Watch part of this week’s Principles of International Tax course for an explanation of ‘Entity Classification‘.

 

Follow us on social media to keep up to date with our ADIT blogs. And don’t be shy, please say hello and let us welcome you to our ADIT community!

 

Stay Informed

Visit our ADITextra blog to find out what else we’ve covered this semester.

Visit our website
Contact us

Follow us on LinkedIn, Twitter & YouTube

 

 

error: Content is protected !!